The Year That Could Happen

There are many reasons why 2026 will be the most impactful year for the appraisal profession since the passage of FIRREA in 1989. Yes, more so than the housing market meltdown of the late 2000’s and the effects of Dodd-Frank’s subsequent passage. Yes, even more than the Covid boom and expansion of appraisal alternative usage in its wake. But unlike those moments, the changes coming in 2026 afford appraisers a real opportunity to shape what comes next.

I know from LinkedIn comments that suggesting direct engagement by those working in the profession gets met with cynicism, a belief that no matter the tone and tenor of comments on various proposals that outcomes are already decided. I understand how viewed from the outside any governmental or quasi-governmental process can seem unwieldy and impossible to affect. But as someone who has seen their words reflected in federal and state laws and regulations simply by engaging in the process, nothing is beyond change so long as you are willing to try.

You know at this point I’m referring to the First Exposure Draft of proposed changes to the Real Property Appraiser Qualification Criteria, the first comprehensive review of what is involved in creating a “minimally qualified” appraiser for the purpose of issuing state appraiser licenses. But there is even more to consider when it comes to 2026 and the opportunities it will present, so let’s unpack everything.

Yes, the Criteria exposure is long and essentially a complete rewrite of something first drafted in the 1990’s. Yes, it comes with additional Concept Papers that address topics not yet ready for an Exposure but worthy of discussion among the profession. And yes, in whatever fashion it becomes finalized it will redefine who and what a real estate appraiser is going forward.

These are good things. For starters, nothing we do in 2026 should be held to ideas first conceived when the Internet barely existed and relied on 28.8 baud dial-up modems. It takes courage to acknowledge that piecemeal changes over the years leave us with something that is neither modern nor effective, and that a complete overhaul is the better approach. And by cleaving off the more complex and detailed ideas into concepts, the AQB accomplishes twin aims: Making big, essential changes now while keeping additional options open down the road.

At this point, you’re probably thinking my view is generally positive on the AQB’s exposure. What I will say: I have views and consciously choose not to express them yet because I’m still forming them. I also do not want my views affecting your views – it is a diversity of perspectives that AQB needs, and not an echo chamber formed around the voices of the few loudest speakers.

From experience, my hunch is we will see a Second Exposure Draft of the Criteria, and it will reflect the comments received from everyone – appraisers, users of appraisal services, appraiser regulators, and anyone else with a vested interest in the future of the profession. As daunting as it may feel, I encourage everyone who is able to provide comments to the AQB using the information linked earlier in this piece.

If all we were processing was the proposed changes to the Criteria, it would be a big year. But simultaneously, the ASB has released its own Exposure Draft for an Advisory Opinion on the use of technology in appraisals and appraisal reviews. This AO seeks to clarify when and how technological tools are used, the level of disclosure required when using tools, and how appraisers and those who rely on their work should consider things like artificial intelligence going forward. It also supersedes existing guidance on prior modeling and analysis tools and seeks to create a single framework that not only works for today’s technology but anything that may emerge going forward.

It is both an ambitious project and one reflective of the thorough examination of the topic performed by the ASB. That said, like any exposure it will benefit from the feedback of those who will rely on the AO, so comments are essential to the refinement and success of the proposed AO.

Beyond those opportunities to provide vital feedback on the direction of the appraisal profession, there are larger market forces that will affect appraisers in 2026 and beyond:

• We fast approach a 2026 selling season where sticky mortgage rates, economic uncertainty, and general consumer pessimism will likely keep sellers and buyers on the sidelines unless necessary.

• At the same time, adoption and use of UAD 3.6 and its updated reporting format will accelerate, and we will see real-time adjustments both to data values and reporting fields; this is a marked change from the prior generation of UAD and its more static nature. Appraisers, real estate agents, mortgage lenders, and consumers will all need to adjust to these changes and effectively communicate why they matter.

• While stalled in 2025, the ROAD to Housing Act and its smaller provisions on appraisal issues will likely come back this year. Whether allowing licensed residential appraisers to perform FHA assignments, codifying the reconsideration of value process, or possibly opening appraisal data to the public, there is a good chance of statutory changes affecting the profession.

• If you’ve seen the LinkedIn feed, there seems to be several retirement and job change announcements every day this new year. Each one of these represents not only a significant life moment for the individual, but opportunity to fill needs for appraisal services of diverse types, not just mortgage lending work. With new entrants to the profession coming in more slowly than those exiting or reducing workloads, it will be left to fewer hands to take up the work in the near term.

• Lastly, I fear the slow-moving disaster that may loom from debt service coverage ratio (DSCR) loans and the role of appraisers in their use by real estate investors. Baltimore is the epicenter of this today, and we may soon find other cities where DSCR products supported by less than scrupulous appraisals may lead to negative headlines for the profession, and the need to message that these exceptions do not represent the overwhelming number of ethical professionals working every day.

2026 will be consequential for professional appraisers, and inaction is simply not an option for anyone who cares deeply about the success of the profession going forward. For anyone who wants help in getting thoughts down on paper, drop me an email and I’ll be happy to assist you in whatever way makes sense. More than anything, use your voice to get others engaged in this pivotal moment nearly four decades on from the passage of FIRREA. Because generational moments come, well, once in a generation.